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HMRC internal manual

Enquiry Manual

From
HM Revenue & Customs
Updated
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Partnerships: Approach to SA Enquiries: Aspect Enquiries

Before issuing a notice of enquiry into the partnership return you should review the files and current year’s returns of all the partners. Where you are not directly responsible for the partners’ files, for example where the partner is dealt with in another office, you should

  • ensure that whoever deals with those partners is made aware of your intention to open an aspect enquiry into the partnership
  • detail the risks you intend to deal with (for example by forwarding a copy of your draft enquiry plan,) and
  • ask for any information held relating to the aspects you are enquiring into to be sent to you.

Update the risks you identified and your enquiry plan on the basis of this further level of review. If necessary consider whether any additional information you have received warrants extending the scope of your enquiry into additional aspects or making it a full enquiry.

If you propose to undertake an enquiry into one or more non-partnership aspects of a partner’s return you should only do so once you or the officer responsible for the partnership have reviewed the partnership as a whole and then only after the issue of the necessary Section 9A notice to the partner. If the partnership is dealt with in another office you should

  • seek the agreement of the officer dealing with the partnership before issuing a Section 9A notice
  • provide details of the risks in the partner’s return that you think need enquiry (for example, by forwarding your draft enquiry plan) in order to assist in the review of the partnership, and
  • ensure that where there are other offices with an interest in other partners they are made aware of your proposed course of action and the reasons for it.

If you receive such a notice make sure that you pass on any relevant information (or advise that your return has yet to be filed) quickly. Use what you have been told to reassess the likelihood that your partner’s return is incorrect or incomplete. Where one partner’s return appears to present a high risk of error or evasion it will sometimes indicate a high risk that the returns of the other partners and the partnership are incorrect or incomplete even though it may not be immediately obvious that this is the case.